After several years of delay, HUD has finally published a proposed rule to implement the second set of revisions to the Part 3280 Manufactured Housing Construction and Safety Standards processed and recommended by the Manufactured Housing Consensus Committee (MHCC). The proposed rule was published in the Federal Register on July 13, 2010. Written comments on the proposal are due on or before September 13, 2010.
Based on an initial brief analysis, it appears that the proposed rule tracks the substance of the revisions recommended by the MHCC, albeit with certain changes in wording. MHARR, however, will conduct a full review of the proposed rule and a comprehensive side-by-side comparison with the MHCC revisions in order to determine whether there have been any substantive modifications by HUD program staff. Following this review, MHARR will submit appropriate comments to HUD on behalf of industry manufacturers.
In the interim, we ask that you please review this document with your company’s technical, regulatory and legal staff and advise MHARR, as soon as possible, of any concerns, questions, or issues that you may have regarding these proposals, so that they can be properly reflected in the Association’s comments to HUD.
On a closely related subject, this is a reminder that comments on HUD’s pending proposed rules on “roof truss testing” and “on-site construction” are due, respectively, on August 16, 2010 and August 23, 2010. Copies of these proposed rules have previously been provided to you by MHARR. We encourage you to forward to us, by July 21, 2010 — if you have not already done so — any comments, concerns, or questions that you may have regarding either of these proposals, so that they can be considered and incorporated in the comments that MHARR will be filing soon on these two rules on behalf of industry manufacturers.
We will continue to keep you apprised of developments affecting all of these proposed rules.
Danny D. Ghorbani, President
Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Ave N.W., Suite 508
Washington, D.C. 20004